Collier v. Adar Hartford Realty, LLC

Summary

The court affirmed the denial of class certification because the proposed class covered all residents over more than fifteen years, while the evidence of common misconduct and uninhabitable conditions primarily concerned 2015 through 2019. The resulting need for individualized proof meant that common issues did not predominate, and the class action was not shown to be superior. Although a trial court may narrow or redefine an overbroad class on its own initiative, it is not required to do so when the plaintiff has not requested a narrower class or subclass.